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[802SEC] FW: IEEE-SA Comments to FTC/DOJ on Standards-Setting - Please reply by 16-April

Dear SEC,
-----Original Message-----
From: []On Behalf Of Joseph L. Koepfinger
Sent: Friday, April 12, 2002 11:40 PM
To: David Ringle;;;;;
Subject: Re: IEEE-SA Comments to FTC/DOJ on Standards-Setting - Please reply by 16-April

To all:
In general this is an excellent discussion of the concerns regarding the pending action by the FTC/DOJ regarding rules and regulations pertaining to patents on the standard development process.
My concern is the appearance that IEEE has done extensive research on the subject of standard development activities where there have been patent problems.  My assumption is base upon the statement in the third paragraph on page 2. If the IEEE has conducted an extensive research, then I would not be concerned about the statement made in the second sentence of this paragraph. If the IEEE has not done an extensive research on this topic it would be desirable to be less empathic.
The document would be strengthen if IEEE would list the number of their standards, that to there knowledge have had to address patent issues. I think that out of th 870 active standards this would be a very small number. In this way IEEE could limit it discussion to what is known about the IEEE patent issues and not become involved in what happens in other Standard Development Organization in with regard to patent issue problems.
Best regards,
Joe Koepfinger
----- Original Message -----
Sent: Friday, April 12, 2002 11:59 AM
Subject: IEEE-SA Comments to FTC/DOJ on Standards-Setting - Please reply by 16-April
Dear All,

Attached are the comments that the IEEE-SA is preparing to send to the
FTC/DOJ in regards to competition and intellectual property in a
standards-setting environment.

Many thanks to Dick Holleman for preparing this text.

Please review the proposed text and send any comments that you have to me
and to Dick [] by 16-April-2002, which will
allow us a little bit of time to make necessary changes and still file the
comments prior to the FTC/DOJ hearing scheduled for 18-April-2002.

Please do NOT reply to all.

Thank you,

David L. Ringle
Senior Administrator, IEEE-SA Governance
IEEE Standards Activities Dept.

445 Hoes Lane                                         PH: +1 732 562 3806
PO Box 1331                                             FX: +1 732 562 1571
Piscataway, NJ  08855-1331       

(See attached file: Draft3-revised.rtf)